European Fat Cats EU Energy Intensive Industries: paid to pollute, not to decarbonise - Climate Action Network Europe
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Contents Executive Summary. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 The Energy Intensive Fat Cats . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 1. Emissions Trading Scheme (ETS) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 2. Cheap electricity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 EU citizens pay with their environment, health and their lives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 Falling behind on innovation and decarbonisation. . . . . . . . . . . . . 12 Carbon Leakage is a pervasive myth with no basis. . . . . . . . . . . . . . . . . . . 13 Opportunities for innovation and decarbonisation . . . . . . . . . . . . 15 Example: steel sector. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 Example: cement sector . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 Investment needed . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 The case of German Fat Cats . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 Conclusion and recommendations. . . . . . . . . . . . . . . . . . . . . . . . . . . 19 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 April 2018 Authors: Julie-Anne Richards, Klaus Röhrig, Maeve McLynn Thanks to: Johan Bosman (CAN Europe), Lena Reuster (FÖS), Sam Van den Plas (WWF), Femke De Jong (Carbon Market Watch) and Suzana Carp (Sandbag). CAN Europe gratefully acknowledges the support of KR Foundation and the European Commission. The content of this publication is the sole responsi- bility of CAN Europe and does not represent the position of the European Union or KR Foundation. © Climate Action Network Europe 2018. This work is licensed under a Creative Commons Attribution-Non Commer- cial Licence (CC BY-NC 4.0).
Executive Summary Energy intensive industry sectors have been among the who are investing heavily in innovation and the upgrade of slowest in the European Union (EU) to reduce their green- their industry and starting to compete in high value seg- house gas emissions and invest in solutions to decarbonise ments formerly led by European industry. and maintain technological leadership. Instead, these sec- tors have been putting a break on more ambitious climate While industry has long used “carbon leakage” (business re- policy, benefitting from watered down regulation, soft tax locating to a country with less stringent climate policies) as deals and preferential pricing. Their efforts to preserve un- an argument to keep the status quo of low ambition, studies rivalled privileges have pushed the cost of dealing with cli- have found no evidence of leakage (Ecorys, 2013). In fact, mate change onto the rest of society. European energy intensive industry pays less for electricity than many competitors, for instance German energy inten- Instead of pursuing real decarbonisation plans, energy in- sive sectors pay roughly 25% less for electricity than the tensive industry in the EU has managed to turn pollution same sectors do in China (Fraunhofer ISI and Ecofys, 2015). into profit: Rather than maintaining the current level of overprotec- • Rather than paying for its pollution under the EU Emis- tion, the EU should be much more concerned about losing sions Trading System (ETS), energy intensive industry is competitiveness in innovative low carbon break-through able to make a cash-grab through a combination of excep- technologies. tions under the scheme. A blatant example are the wind- fall profits from excess emission allowances that industry EU energy intensive industry must face the inevitable need actors initially received for free amounting to over €25 to decarbonise and stop undermining ambitious climate pol- billion during 2008-2015. At the same time, EU govern- icy. Instead, the sectors can embrace the opportunities of in- ments missed out on €143 billion in revenue due to free novation and the circular economy through forward-looking allocation of pollution permits during the same period of approaches. time. Even after a recent reform, the EU ETS will contin- ue to issue free allowances to energy intensive industry At the same time, policy makers and regulators need to es- sectors which means that public revenues amounting to tablish certainty about the necessary pathway for decarbon- around €380 billion will be foregone by EU governments isation in the coming decades. The UNFCCC has launched between 2008 and 2030. a yearlong exchange on how countries can ratchet up their • Energy intensive industry receives extremely generous climate commitments, the so-called Talanoa Dialogue. This tax breaks. For example in Germany, households pay makes 2018 an important year for kick-starting the process nearly twice as much for their electricity as energy in- and momentum to increase global climate ambition. It thus tensive industry sectors with total financial gains from tax provides the impetus for the EU to reboot its policy approach schemes amounting to over €17 billion in 2016, roughly to energy intensive industry; making it clear that it will con- the same as the 2017 German federal budget for research tribute to, rather than detract from EU climate ambition. and education; Governments need to substantially reshape their current • European governments still provide nearly €15 billion of approach of massive government subsidies for energy inten- fiscal support that encourages consumption of fossil fu- sive industry to pollute, and rather make them pay for pol- els in industry and business each year. lution. This would provide industry and EU governments an incentive to invest in and to commit to innovation. As a result of these subsidies to energy intensive industry and its delayed action on decarbonisation, citizens pick In addition, under the Paris Agreement, member states and up the bill for climate change and air pollution. They are the EU need to communicate long term greenhouse gas increasingly paying with their health and lives: each year emission development strategies to the UN, outlining how 231,554 Europeans die prematurely due to air pollution, they intend to mitigate emissions until mid-century. On 22 almost a quarter of which comes from energy intensive in- March this year, the European Council invited the European dustry. In addition, average annual health costs associated Commission to present a draft of such a long term strategy in with air pollution amount to at least €215 billion. early 2019 (European Council, 2018). It is crucial that these strategies set out pathways that ensure that every sector of Subsidies such as tax breaks, hand-outs and insufficient the economy contributes substantially to the objective of emission reduction targets have given European energy in- the Paris Agreement, namely keeping global temperature tensive industry little incentive to innovate and decarbonise. rise well below 2 degrees and pursue efforts to limit temper- It is falling behind competitors in other regions, like China, ature rise to 1.5 degrees. 3 EU ENERGY INTENSIVE INDUSTRIES: PAID TO POLLUTE, NOT TO DEC ARBONISE
Policy Recommendations In particular, the EU needs to rethink its current industrial approach and consider the following policy recommendations: Make clear that energy intensive industry sectors will be required to fully decarbon- ise before 2050, setting stretch goals for the various sectors as markers along the way. The European Commission should develop its draft long term climate strategy as soon as possible, sketching out the possible pathways to decarbonise the Euro- pean economy before mid-century in ways compatible with the 1.5 and 2 degrees Celcius target of the Paris Agreement. Based on the draft Long Term Strategy, the European Commission should devel- op pathways for the ambitious decarbonisation of energy intensive industries. It should do so in consultation with existing expert groups such as the High level group on energy intensive industries or the High level industrial roundtable ‘Industry 2030’, bringing together stakeholders including governments, industry, trade unions, academics and civil society. This exercise could help sectors to update existing indus- try-specific roadmaps toward full decarbonisation or start drafting those embedded in a cross-sectoral roadmap that is aligned with the Paris Agreement. Both the sectoral as well as the horizontal roadmaps should pay particular attention to address energy poverty and provide measures to support just transition plans for affected communities and workers in industries that must, by necessity, phase down and be replaced with zero carbon alternatives. The rules of the EU ETS need to be revised and tightened in light of the long term tar- gets of the Paris Agreement by strengthening the cap, cancelling surplus allowances and ensuring that the polluter-pays-principle is respected in all sectors covered by the scheme. The funds created under the EU ETS should not hamper the necessary decarbonisa- tion of industry sectors. Rules should be toughened to ensure that the Innovation Fund is not simply used to pad industry profits, but supports low carbon technology for short term use, and zero carbon technologies to deliver the necessary decarbon- isation and emission reduction pathway. As the prime beneficiary of these funds, in- dustry needs to start paying for its emission allowances. The free allocation of pollu- tion permits under the ETS needs to be phased out. It is clear that the ETS alone will not be enough. Complementary policies are neces- sary, both at EU and at national level. The first opportunity is the establishment of adequate and credible 2030 targets for the deployment of renewable energy and en- ergy savings at EU level. The European Commission should encourage member states to strengthen carbon pricing, for example through a common carbon floor price and look into additional measures to complement the insufficient ETS framework at the EU level. Finally, the European Commission should consider the setting of Emission Performance Standards for the production of resource and energy intensive materials. Member states should assess all national policies addressed at industry, including taxation policy, and ensure that it supports, not undermines, a transition to a zero carbon industry. Progress towards policy change should be reported through existing frameworks such as the European Semester. 4 EU ENERGY INTENSIVE INDUSTRIES: PAID TO POLLUTE, NOT TO DEC ARBONISE
Introduction European citizens are acutely aware of the challenge of cli- In the short term, the EU is not on track to meet its own, inad- mate change. Three-quarters (74%) consider climate change equate, 2030 target of 40% emission reductions compared to be very serious and 92% see it as a serious problem (EC to 1990 (see graph). Additional measures will be necessary 2017c). They rightly demand action, with nearly 90% of Eu- to put the EU on a decarbonisation pathway. This report lays ropeans ranking government efforts to increase renewable out key measures for one of the most polluting industries. energy as important. The majority sees the responsibility to act almost equally divided among industry, the European Energy intensive industries can take a portion of the re- Union (EU) and national lawmakers. Historically the EU has sponsibility for this shortfall in climate action. They have prided itself on climate leadership – with a legacy of ambi- acted as an ‘anchor’ on EU climate policy, slowing down am- tious rhetoric, alliance building and action. bition and benefitting from watered down regulation, soft tax deals and preferential pricing. Preferential treatment Against this backdrop, the EU’s level of climate ambition is dis- for energy intensive industry has padded their bottom line appointing. Current EU climate policies are not up to the task and pushed the price of dealing with climate change onto of avoiding dangerous climate change and protecting the EU the rest of society, while the industry has done too little to economy and its citizens against significant climate impacts. pursue real solutions to decarbonise. The European Commission’s current zero carbon economy This report outlines how skewed current EU policies are to- roadmap sets an aspirational goal of reducing greenhouse gas wards big polluting industries and how this has pushed the emissions by 80-95% by 2050 (EC 2011). However, in order to need and costs of climate action, and the impacts of pollu- be compliant with the Paris Agreement, the EU’s goal must be tion and climate change, onto European citizens. to reduce greenhouse gas emissions to zero well before 2050. GRAPH 1: Progress towards meeting Europe 2020 and 2030 greenhouse gas reduction targets Mt CO2 equivalent 6,000 5,500 5,000 -20% compared to 1990 4,500 -23% in 2016 4,000 3,500 -40% compared to 1990 3,000 1990 1995 2000 2005 2010 2015 2020 2025 2030 Historic emissions Projections with existing measures -WEM- (based on MS submissions) Proposed greenhouse gas emissions trajectory Source: EC November 2017 5 EU ENERGY INTENSIVE INDUSTRIES: PAID TO POLLUTE, NOT TO DEC ARBONISE
The Energy Intensive Fat Cats Energy intensive industry includes iron and steel, cement, 2016). In fact, while emissions of energy generators have chemicals, refineries, copper, aluminium, paper, ceramic, been going down, emission levels from industry covered by lime, ferro-alloy, chlor-alkali, gypsum, metal, clay, petrole- the EU Emissions Trading System - mainly energy intensive um, and glass producers. These sectors use a high propor- industry - have stagnated since 2012 and are expected to tion of the total energy consumed globally (37%) and in stay constant until beyond 2030 (see graph below). This addition some industrial processes produce carbon dioxide standstill is totally at odds with the overall EU’s commitment directly as a by-product, for example cement manufactur- to the Paris Agreement. ing (Napp 2016). In the EU, energy intensive industry is re- sponsible for almost a quarter (23%) of air pollution (AMEC Energy intensive industries have followed an overall “busi- 2014) and roughly a fifth (19.3%) of total greenhouse gas ness as usual” approach, focusing emission reduction ef- emissions.1 forts on the low hanging fruit of efficiency – which offers limited gains in these industries. Ex-post evaluation of cli- Despite greenhouse gas emissions falling in other industries mate policies shows that it is innovation, not small efficien- in the EU, including the electricity sector, progress in the cy improvements, that is the main driver to lower emission energy intensive industries remains slow (CEPS 2017, Napp intensity (EC 2017e). GRAPH 2: Greenhouse gas emission trends and projections under the scope of the EU ETS, 1990-2030 MtCO2e 1,800 1,600 1,400 1,200 1,000 800 600 400 200 0 1990 1995 2000 2005 2010 2015 2020 2025 2030 2035 Notes: Energy industries • In this graph, ‘energy industries’ refers to energy producing installations (utilities), Other stationary installations while energy intensive industry is represented by ‘other stationary installations’. Aviation • Solid lines represent historical GHG emissions (available for the 1990-2016 peri- od). Dashed lines represent projections of the WEM scenario. Dotted lines repre- sent projections under the WAM scenario. • The EU ETS GHG emissions presented were estimated based on the attribution of GHG emissions, reported by source categories in national GHG inventories and na- tional projections, to EU ETS sectors and/or Effort Sharing sectors. Sources: EEA, 2017a, 2017b, 2017c, 2017d. 1 Calculated as the sum of greenhouse gas emissions from Fuel combustion in manufacturing industries and construction: 483.40249 and Industrial processes and product use: 373.93741 calculated as a portion of All sec- tors: 4,451.81256 from Eurostat 2016a. 6 EU ENERGY INTENSIVE INDUSTRIES: PAID TO POLLUTE, NOT TO DEC ARBONISE
One can acknowledge the reductions in greenhouse gas emis- The ETS sets a cap on the total amount of greenhouse gases sions achieved by energy intensive industries since 1990. allowed from power stations, industrial plants and relevant But the standstill of industrial decarbonisation since 2012 airlines. Within the cap, power generators and industrial and expected future trends show that those sectors have not installations buy or receive emission allowances for every taken responsibility for their role in contributing to climate tonne of carbon they emit. The cap should reduce each year change and have not made the necessary effort or investment so that total emissions fall. Emission allowances can be trad- to decarbonise. They have instead fostered and benefitted ed, so that the least expensive emissions are reduced first. from policy settings that, rather than providing incentives to innovate and reduce carbon, have made it profitable to pol- However, the EU ETS is not fit for purpose and rather than lute. The result is an inefficient and polluting industry in the driving emission reductions in energy intensive industry, it EU that has pushed the cost and consequences of climate puts a break on the needed decarbonisation in these sectors. change onto European citizens and other industries. Even worse, it has been turned into a subsidy vehicle. Energy intensive industries have been making money from The first problem is that the caps have been set at too gen- polluting in the following key ways: erous a level and not adjusted downward as it became clear they were not driving emission reductions from industry. The graph below shows that the ETS caps (in black) are higher 1. Emissions Trading Scheme (ETS) than current emissions (in green) and significantly higher than projected emissions (in yellow), meaning that industry The EU ETS is supposed to be Europe’s main policy driver to covered by the ETS has to take little or no effort to meet the reduce emissions. It covers power generators, aviation and caps. In fact, the majority of emission reductions have been a energy intensive industries – around 45% of total EU emis- result of the global economic downturn and mainly achieved sions (EC no date). by lower production, not by reduced emissions intensity (Sandbag 2017b). GRAPH 3: ETS greenhouse gas emission reductions estimates up to 2030 100% 80% 60% 40% 20% 0% ‘05 ‘06 ‘07 ‘08 ‘09 ‘10 ‘11 ‘12 ‘13 ‘14 ‘15 ‘16 ‘17 ‘18 ‘19 ‘20 ‘21 ‘22 ‘23 ‘24 ‘25 ‘26 ‘27 ‘28 ‘29 ‘30 Sandbag projections COM IA 2009/29/EC projections Cap ETS emissions (scope 13-20) COM IA 2030 GHG40 projections 1% yearly reduction from 2016 EUCO30 projections Source: Sandbag 2017a 7 EU ENERGY INTENSIVE INDUSTRIES: PAID TO POLLUTE, NOT TO DEC ARBONISE
Finland €517 Sweden MAP: Windfall profits made €792 by companies in EU Member United Kingdom States in million € Denmark €3,152 €243 Ireland €217 Netherlands €1,164 Germany Poland Belgium €4,705 €1,043 €1,487 Luxembourg Czech Republic €42 Slovakia €702 €849 Austria France €443 Hungary €2,817 €225 Slovenia €41 Portugal €468 Spain TOTAL €2,963 Italy from 20 countries €2,441 €25,011 Greece €700 Source: Carbon Market Watch 2016 TABLE 1: Profits made by energy intensive industry through the EU ETS Sector Windfall profits from Windfall profits from Windfall profits from Total windfall profits surplus ooffsets minimum cost-pass through Iron and Steel €784 million €239 million €7,364 million €8.4 billion Cement €2,729 million €149 million €2,083 million €5.0 billion Refineries -€67 million €86 million €4,562 million €4.6 billion Petrochemicals €774 million €42 million €901 million €1.7 billion Source: Carbon Market Watch 2016 In addition, the EU ETS rules have allowed industry to make Due to lenient caps on greenhouse gas emission allow- a cash-grab from this lack of action. Energy intensive indus- ances, industry received more emission allowances for tries were given their emission allowances for free, rather free than it actually needed. Industry actors then sold the than having to buy them in auctions. They then increased surplus allowances on the market – netting a further €7.5 the cost of their products for the theoretical value of these billion in windfall profits. For some of their emission reduc- allowances – charging their customers for costs that they did tion requirements, industry was able to use cheap offsets not pay. The charge (or “pass through”) of non-existent costs from non EU countries to meet targets – thus freeing up EU earned industry windfall profits of €16.8 billion from 2008 ETS allowances which they sold for a further profit of €0.8 until 2015. In Germany alone, industry gained over €3.5 bil- billion. In total, energy intensive industry made over €25 lion from this windfall profit (CE Delft 2016 and Carbon Mar- billion in windfall profits from the EU ETS during 2008- ket Watch 2016). 2015. Tata Steel UK Limited alone made over €1 billion in windfall profits from the EU ETS from 2008 until 2015 (CE Giving away free emission allowances undermines the pol- Delft 2016 and Carbon Market Watch 2016). luter-pays principle, and reduces the incentive for com- panies to produce more efficiently or to invest in break- through technologies to reduce pollution (Carbon Market Watch 2016). It also pushes the responsibility for reducing emissions and meeting overall EU targets onto other sectors of the economy. 8 EU ENERGY INTENSIVE INDUSTRIES: PAID TO POLLUTE, NOT TO DEC ARBONISE
TABLE 2: Companies making the biggest windfall profit* from the EU ETS, 2008-2015 Company Industry sector CO2 overallocation Total windfall profits* in Country kiloton 2008-2015 million € 2008-2015 Tata Steel UK Limited Iron and steel 4,866 €1140.4 UK U. S. Steel Košice sro Iron and steel 1,646 €653.1 Slovakia ArcelorMittal Germany Iron and steel 27,443 €641.8 Germany ILVA S.P.A. Iron and steel 11,840 €628.2 Italy ArcelorMittal España, s.a. Iron and steel 17,446 €605.5 Spain ArcelorMittal Belgium Iron and steel (incl 10,751 €509.8 Belgium coke oven products) Hüttenwerke Krupp Iron and steel 14,288 €489.7 Germany Mannesmann GmbH Tata Steel IJmulden B.V. Iron and steel 1,447 €439.9 Netherlands *Profits are an estimate of windfall profits from surplus, offsets and from passing the cost through to buyers. Source: CE Delft 2016 As a result of giving emission allowances away for free – (in an overall electricity price of €110/MWh), whereas house- rather than selling them to industry – EU governments lost holds pay €79/MWh in taxes and levies bringing their elec- out on potential auctioning revenue of at least €143 billion tricity price up to roughly €210/MWh – nearly double of that from 2008 until 2015. That money could have been availa- paid by industry (EC 2016). In Germany alone, households ble for investments in the climate-friendly transition of the pay roughly two billion Euros more each year for electricity European economy (CE Delft in Carbon Market Watch 2016). to make up for the subsidies that energy intensive industries receive. And once other industries and service sectors of the ETS rules have discouraged innovation and restructuring. Un- economy are included, the debt mounts to €4.5 billion each til 2012, industry was receiving free allowances on the basis year (Fraunhofer ISI and Ecofys 2015). of their historic emissions, rather than actual performance. Their free allowances therefore did not take into account For example, the average German household pays over falls in demand or improvements in efficiency, and as a re- 16 €ct/kWh for electricity, whereas in 2014 German energy sult they lacked incentives to reduce emissions. Aggravating intensive industry paid less than 5 €ct/kWh for electricity the problem were emission allocation rules that encouraged (Fraunhofer ISI and Ecofys 2015). This is a straight shift of companies to keep installations open (otherwise they lost the levies designed to cover the cost of developing renewa- their free allowances). In cement manufacturing, these rules ble energy and protecting the environment, and other taxes, have resulted in approximately 5.2 million tonnes of excess from industry to households. CO2 emissions in 2012 (Neuhoff et al 2015). The combination of inadequate caps, overgenerous free 3. Fossil fuel subsidies allowances and accumulated surplus permits, keeps the carbon price within the EU ETS low. This allows Europe’s Despite committing to phase out subsidies to fossil fuels industry to continue polluting on the cheap whilst the rest many times, governments across the EU continue to provide of society picks up the bill of climate impacts. Even after a subsidies to fossil fuel production and consumption. EU recent reform2, the EU ETS is not expected to drive emission countries and the EU itself provided nearly €15 billion per reductions fast enough. year in subsidies to fossil fuel industry and business through fiscal support, including tax breaks for energy use, and price and income support for energy intensive companies and 2. Cheap electricity processes (Gençsü et al 2017). Energy intensive industries also receive subsidies on their As energy intensive industry uses roughly 20% of Europe’s electricity prices – padding their bottom line and profit, en- energy3 and taps into fossil fuels directly as feedstock, it couraging them to be more wasteful with energy and pollut- therefore benefits materially from the subsidies that Euro- ing more. These electricity subsidies to heavy industry push pean governments still provide to fossil fuels. the costs of electricity onto the rest of society. EU-wide in- dustry pays only €34/MWh of taxes and levies on electricity 3 20% is calculated from Eurostat (2016b) p8 by adding the energy used by 2 The phase IV reform was concluded in December 2017 and will come into iron and steel, chemical, metals, minerals, machinery, mining, paper, wood effect from 2021-2030. products, textile and other industries against total energy used. 9 EU ENERGY INTENSIVE INDUSTRIES: PAID TO POLLUTE, NOT TO DEC ARBONISE
European Banks A number of examples identified in ‘Phase-out 2020: Moni- In addition to national subsidies, European banks toring Europe’s Fossil Fuel Subsidies’ are highlighted below provide support to fossil fuel extraction and use to indicate some of the methods used to support fossil fuel – keeping costs for fossil fuels low and therefore use in energy intensive industry4: benefitting energy intensive industry. The Euro- pean Investment Bank (EIB) provided €7 billion in In France, reduced ‘contributions for the public service of funding for fossil fuel projects from 2013 to 2015. electricity’ were applied to electricity consumed by indus- It also lent €38.4 million for co-fired generation of trial facilities, hyper-electricity intensive facilities and other biomass and coal in 2015, and, at the end of 2015, industrial complexes (currently in operation), resulting in an approved a €600 million loan to a Spanish com- annual average expenditure of €555 million in 2015-2016 pany for gas pipeline infrastructure, (CAN Europe (or €33 million per year given that fossil fuels contribute 6% 2016 and HEAL 2017). These subsidies directly or of electricity generation. ODI and CAN Europe (2017) high- indirectly benefit heavy industry by making their light that other tax exemptions awarded to energy intensive inputs, including electricity, cheaper. industry included tax waivers on the final consumption of electricity for the use of electricity in certain industrial pro- Another example comes from the European Bank cesses and in geographies where energy is produced. for Reconstruction and Development (EBRD), which made investments of €2.5 billion in fossil fuels In Poland, energy intensive industry is granted a tax exemp- from 2014 to 2016 (Gençsü et al 2017). Meanwhile, tion on use of natural gas. In general industries are com- the Connecting Europe Facility, which is designed mitted to pay a tax of €1.10/MWh, but industries with en- to expand cross-border infrastructure, is being used ergy intensity above 5% are exempted from the excise tax to fund gas pipelines – €800 million between 2014 (Gençsü et al. 2017). Coal is exempt from excise duty if it is and 2016. However, by far the biggest gas pipeline used by energy intensive industry for heating purposes, and project (€40 billion) is the Southern Gas Corridor by business entities that implement systems aiming to fos- which aims to link Azerbaijani gas fields to consum- ter environmental protection or increase energy efficiency ers as far away as Italy by 2020. EIB and EBRD loans (OECD, 2012). for the Albania-Greece-Italy section are expected to be the biggest single loans in the history of either In the UK, support provided to industry, through climate of these two banks (HEAL 2017). change levy discounts and exemptions, is estimated at an av- erage of £224 million (€287 million) per year between 2014 and 2016 (HMRC, 2017a; 2017b). The climate change levy is a tax on energy use by non-domestic users to support energy efficiency and reduce carbon emissions. 4 For a full overview of the findings on subsidies to energy intensive industry please see country studies: https://www.odi.org/publica- tions/10939-phase-out-2020-monitoring-europes-fossil-fuel-subsidies 10 EU ENERGY INTENSIVE INDUSTRIES: PAID TO POLLUTE, NOT TO DEC ARBONISE
EU citizens pay with their environment, health and their lives European citizens pay more for their electricity, and higher The Health and Environmental Alliance (HEAL) estimates that taxes to fund these subsidies to energy intensive industries. already 231,554 Europeans die prematurely due to air pol- They pay a third time when they face the cost of climate lution which mostly comes from fossil fuels – including in change from heavy industries climate pollution. industry and transport (World Bank 2016). In addition, the average annual health costs associated with air pollution According to the European Environment Agency (EEA), cli- stand at €215 billion (Coady et al 2015 in HEAL 2017). mate change is expected to cost the EU around €190 billion a year by the end of the century. Southern Europe will be hit Heavy industry is responsible for almost one quarter (23%) particularly hard, with Mediterranean countries potentially of air pollution emissions (AMEC 2014), contributing directly losing 1.2% of GDP by 2050. In addition to higher temper- to the large health costs brought on by air pollution. atures, more droughts and heat waves, rising sea levels, more river flooding, impacts on tourism in southern regions and low altitude ski slopes, climate change could lead to a 20% increase in food prices, reduced well-being and many additional deaths (EEA 2016 p283-285). The societal and economic consequences of climate change are already happening today. The EEA highlights that report- ed economic losses caused by climate-related extremes in EU countries from 1980 to 2016 were approximately €410 billion. Since 1990, average annual losses have been over €11 billion (EEA 2018). 11 EU ENERGY INTENSIVE INDUSTRIES: PAID TO POLLUTE, NOT TO DEC ARBONISE
Falling behind on innovation and decarbonisation The perverse incentives within the EU ETS, combined with Adding up foregone revenues due to free allocation since the many other subsidies European energy intensive indus- 2008 and the estimated value of free allowances issued dur- try receives, have undermined the incentive for these indus- ing the next ETS trading phase, EU governments miss out on trial sectors to invest in break-through technologies to inno- a total of €380 billion between 2008 and 2030 (Trilling et vate and decarbonise. A wide range of technological options al. 2017). This loss actually weighs twice for the taxpayer: as to reduce emissions in carbon intensive sectors remain un- the actual public revenue loss which could have been used exploited (including efficiency gains and new technologies to cover social and climate-related expenses, but also as the that will be explored in the following section). Consequently, price current and future generations have to pay for the costs industrial emissions are not projected to go down from now and damages of unmitigated climate change and persistent until 2030 (Carbon Market Watch 2016). air pollution. Despite the modest improvements in the EU ETS agreed as What’s more, the global economic downturn has resulted in part of the Phase IV revision5, the main opportunities to turn declining demand for the products of many energy inten- the ETS into a meaningful policy tool to drive towards low sive industry sectors, such as steel and cement manufac- emissions and innovation have been missed. Rather, the ETS turing, and have subsequently caused overcapacity. During continues to protect incumbents and work against innova- this period, an unhealthy reliance on government subsidies tion (Sandbag 2017). It is particularly disappointing that and perverse incentives to maintain the status quo have the detrimental practice of handing out free allowances will slowed down EU energy intensive industry’s drive to invest continue during the next phase, with the EU set to give out and innovate. They are losing ground to competitors, as de- 6.3 billion allowances to energy intensive industry for free, scribed below. worth approximately €160 billion (WWF 2017). Investment in innovation and other intangible assets re- Free allocation of emission allowances in the EU ETS means mains lower in the EU than in many competitors, who are that European Governments have lost a valuable source of investing heavily in the upgrade of their industry. The EU’s income to invest in the low carbon transition and innova- innovation gap is increasing as EU industry’s drive to adopt tion. Between 2008 and 2015, almost 11.8 billion allow- the new, disruptive technologies required by a circular ances were given away for free with a potential value of economy (outlined further in this report) is blunted by the €143 billion (CE Delft in Carbon Market Watch 2016). This deceptively soft bed of subsidies, tax breaks, cheap ener- €143 billion in lost revenues could have made up a signifi- gy and a flawed ETS. Major economic players like China are cant chunk of the climate investment gap, the €177 billion investing heavily in research and development, design and gap in investment needed to meet climate and energy tar- trademarks (EC 2017b) and starting to compete precisely gets across the EU (EEA 2017). in those higher added value segments where Europe tradi- tionally did best (EC 2017c). 5 Including voluntary unilateral cancellation of emission allowances by Member States, double surrender as translated into an increased MSR (Market Stability Reserve) intake rate, and cancellation of 3 billion tonnes of CO2 from the surplus. For more detail see: https://sandbag.org. uk/2017/11/14/eu-fails-show-leadership-cop23-analysis-ets-reform/ 12 EU ENERGY INTENSIVE INDUSTRIES: PAID TO POLLUTE, NOT TO DEC ARBONISE
The EU and its member states need to turn this situation Carbon Leakage is a pervasive around and stimulate more capital investment and facili- myth with no basis tate the uptake of promising innovation. The EU also needs to strengthen its enabling environment to ensure that its Many of the subsidies to industry are based on the claim risk-bearing disruptive innovations will create new markets from energy intensive industry that they need protection and industrial leadership in Europe rather than outside (EC from “leakage” – that is, the risk of businesses relocating 2017c). It could do this by following the advice of its sus- to a country with less stringent climate targets and laws, tainable expert groups which have recommended to clas- thereby shifting production from a “low emitting” area to a sify finance and investment in terms of their contribution “high emitting” area. to sustainability, encourage investment in areas of circular resource management, instead of the continuous through- However, “leakage” is a myth that has no basis in fact. Numer- put of energy and materials, and instill long term thinking ous studies have found no evidence of leakage, or produc- in investment decisions (High Level Expert Group on Sus- tion displacement, deriving from the EU ETS. In 2013, a study tainable Finance 2018). done for the European Commission concluded: “We found no evidence for any “carbon leakage” in energy intensive sec- Ironically, it is the very structures created within the EU tors in the past two ETS periods” (Ecofys 2013). A recent aca- which, rather than establishing an “enabling environment” demic paper, the first ever analysis to quantify the effect that and long term circular thinking, pull the rug out from under energy prices have on global trade, found that that the pros- it. Reversing the perverse subsidies and contradictory incen- pects of EU companies moving their production abroad due tives identified earlier in this report would be a significant to more ambitious climate policies is ‘extremely limited’. A step towards the objectives the EU has set on innovation, cir- ten-fold increase in the carbon price would, according to the cular economy and greenhouse gas emissions. researchers, only marginally affect imports and exports, even with the phase-out of free emission allowances and 100% auctioning (Carbon Market Watch 2016 and Sato and Deche- zleprêtre 2015). After the recent phase IV reform of the ETS, the carbon price is only expected to rise modestly (with estimates from lit- tle impact on today’s low price of around €10-12 per tonne CO2 to a high estimate of €38 by 2030), noting that previ- ous forecasts have consistently overestimated prices (Evans 2017). Even at the high end, these prices are not at half the levels needed to provide sufficient incentives to meet the commitments made under the Paris Agreement.6 Any risk of leakage is only decreasing. With the Paris Agreement in place, all countries have now agreed to take action to keep warming well below 2 degrees and pursue effort to limit warming to 1.5 degrees Celsius, ensuring it stays well below 2 degrees Celsius – making null and void the carbon leakage argument. China is set to launch its national ETS and has been trialling emissions trading schemes since 2013-14 across five cities and two provinc- es, covering 1,373 Mt CO2, and achieving high compliance 6 The report of the High-level Commission on Carbon Prices suggested that the carbon price levels needed to achieve the Paris temperature target are at least US$40–80/tCO2 by 2020 and US$50–100/tCO2 by 2030 (Carbon Pricing Leadership Coalition, 2017). 13 EU ENERGY INTENSIVE INDUSTRIES: PAID TO POLLUTE, NOT TO DEC ARBONISE
rates. Prices in these pilot markets have been comparable than most of the EU’s trading partners; for example, China, to the EU ETS, generally below 60 yuan/tonne (€7.62) and Japan and Russia.7 with an average of approximately 30 yuan/tonne (€3.81). Surely, domestic energy intensive industry also receives Energy intensive industry in Europe receives more subsi- generous protection in China, but with the largest global dies for its electricity than the same industries in Canada, emitter moving, momentum on increasing global climate US, Korea, China and Japan. For example, in Germany elec- ambition is growing. tricity prices for big industry are halved by government subsidies to less than 5 €ct/kWh – whereas Chinese indus- On introduction of its national market in 2019, Chinese try pays more than 6 €ct/kWh for electricity – at least 20% emissions trading will cover approximately one-third of the more, as demonstrated in the graph below (Fraunhofer ISI country’s carbon emissions (3,500 Mt CO2) – almost twice and Ecofys 2015). the size of the EU market (Pike and Zhe 2017). Other coun- tries have committed to climate action, and are being held Additionally, EU industry lost market share to China in to account, within the Paris Climate Agreement, with an in- steel, paper and aluminium, despite energy costs in the EU creasing number stepping up their efforts. being lower than in China (Ecofys et al 2016). EU energy intensive industry needs to stop hiding behind the carbon When taking into account the costs of energy paid by en- leakage argument, and instead embrace innovation, decar- ergy intensive industry, we see that energy costs for the bonisation and a circular economy. What follows is a recipe manufacturing industry in the EU are substantially lower for this change. GRAPH 4: Electricity prices for big companies Calculated electricity price (€ct/kWh) 14 Renewables and environment Taxes and levies 12 Transmission and distribution Energy procurement 10 8 DE: electricity price in Germany in 2013 for energy intensive 6 industries; (DE): what the price is without 4 special deals for industry. 2 0 DE (DE) NL FR UK IT DK CA US KR CN JP Source: Fraunhofer ISI and Ecofys (2015) 7 Real unit energy costs (RUEC) – combine energy prices and energy inten- sity to assess the significance of energy costs in the manufacturing sector. Results are presented as percentage of value added for the manufacturing sector (excl. refineries). For full overview of costs per EU Member State please see graph 3.5.22: https://ec.europa.eu/commission/sites/beta-po- litical/files/swd-energy-union-key-indicators_en.pdf 14 EU ENERGY INTENSIVE INDUSTRIES: PAID TO POLLUTE, NOT TO DEC ARBONISE
Opportunities for innovation and decarbonisation Current policy settings and schemes allow energy intensive will require a far more holistic approach with wide-reaching industry to continue on a high carbon pathway, propped up changes to industrial sub-sectors. For example, the circular by tax payers and losing ground to key competitors on the economy concept will decrease demand for industrial prod- innovation front. There are alternative pathways, that will re- ucts and necessarily replace high carbon products with zero quire government and industry to face up to the new global carbon alternatives. It will also require targeted research, de- environment for heavy industry, the need for urgent climate velopment and deployment efforts to accelerate the avail- action, and the opportunities of both. ability of new technology and options (drawing on Circle Economy & Ecofys 2016, CAT 2017). Examples of the steel Whilst improvements in efficiency and decarbonisation of and cement sectors are presented below to demonstrate the the energy supply can lead to modest emissions reductions huge shift required from current thinking and pathways to a (CAT 2017), this “low hanging fruit” has largely been uti- zero carbon mentality and pathway. lised, and deeper, more substantial changes are essential. The biggest energy intensive industry sectors, such as steel, Bringing this innovation on quickly, in the timeframe de- aluminium, cement, chemicals and refineries, all require manded by climate change, will require massive targeted myriad of new technologies and production processes if an investments in innovation and capital intensive transforma- economy-wide target such as a 95% reduction commitment tion. It has to be ensured that industry cannot receive these is to be credible (CEPS 2017) including the following options investments to simply pad their profits, but they must be used (drawing on Wyns and Axelson 2016, CAT 2017): to decarbonise and innovate. See the investment section be- low for how the capital for those needs could be generated • Developing new process technologies such as a new through pollution pricing, and how it could be deployed. type of blast furnace that does not require coking coal, oil-based inputs being replaced with other lower carbon inputs in the chemical industry; Example: steel sector • Introducing innovative products such as clinker substi- Much of the emission reductions from steel production in tute to replace Portland cement, new high performance the EU is a result of falling production. Production peaked and lightweight steel, chemical compounds that can be in 2007 at 210 Mt and has since decreased by 21% in 2015 assembled from bio-based feedstock; (World Steel Association 2016b in Sterl et al 2017). EU steel production is projected to grow at the modest rate of 0.8% • Transition business models including for example, fer- per year to 2050 (Boston Consulting Group & Steel Institute tilizer producers moving from pure manufacturing into VDEh 2013 in Sterl et al 2017). agricultural service provision utilizing emerging bio- technologies, the cement and steel industries address- The graph on the next page shows three projected path- ing overcapacity and responding to lower sales volumes ways: current trends, decarbonisation and steps towards through rationalisation, modernisation and increased circularity, which include optimisation of the energy and overall value added; emissions performance of existing production routes, such as increasing process integration, using process gas streams • Align with other major shifts, for instance the electrifica- or capturing the emitted carbon, and recycling scrap steel tion of ammonia and steel production could allow these within manufacturing (Sterl et al 2017). The fact that even processes to act as a battery, balancing a grid with high the most optimistic projection falls dramatically short of levels of renewables, reconfigure industries to fit within the EU 2050 80-95% greenhouse gas reduction target, new resource efficiency and circular economy models via demonstrates the significant additional investment that adopting business models based on re-use and recycling. is required, and how the industry will be required to think outside the box – requiring an altogether different set of Reaching zero carbon for energy intensive industry will re- policy levers to be in place than soft targets, free allowanc- quire not only improvements in efficiency, but shifting to es and subsidised electricity. It also speaks to the need for clean inputs and the decarbonisation of the energy supply. It society to look for replacements for steel where possible. 15 EU ENERGY INTENSIVE INDUSTRIES: PAID TO POLLUTE, NOT TO DEC ARBONISE
GRAPH 5: EU Emissions from Steel (MtCO2/year) The graph below right incorporates projections of emissions from the EU cement industry, showing that on current trends emissions are likely to remain constant. 300 With strong efforts, including 20% of demand reduced via 200 product substitution, emissions are projected to follow path C. This includes partial substitution of the cement needed for concrete production by using aggregates of 100 cement with e.g. crushed concrete (Fischedick et al. 2014 in Sterl et al 2017), wood waste ash from biomass combus- 0 tion (Ban & Ramli 2011; Turgut 2007 in Sterl et al 2017), 1990 2000 2010 2020 2030 2040 2050 cotton waste from the spinning industry, and limestone powder waste from limestone processing factories (Algin & Current trends Turgut 2008 in Sterl et al 2017). Alternatively, it could be a Decarbonisation full replacement of concrete with other materials, such as Steps towards circularity steel or aluminium (which, however, should have their own Electricity-related emissions decarbonisation pathways that may require reductions in Direct energy-related emissions production), Cross-Laminated Timber (Circle Economy & Ecofys 2016 in Sterl et al 2017), or cement-free concrete, Source: Sterl et al (2017) such as alkali-activated concrete (Neuhoff et al. 2014; Bilek et al. 2016 in Sterl et al 2017). One positive example is the initiative from SSAB, LKAB and Vattenfall to create fossil-free steel, the HYBRIT project, This modelling demonstrates that with substantial emissions 50% funded by the Swedish Energy Agency. Starting with remaining, innovative options will be necessary (Sterl et al reforming mining, and also utilizing hydrogen produced by 2017) and must urgently be developed. Again, current policy renewable energy, the aim is to be fossil-free by 2045. In settings provide no incentive for this work to begin. the short term, blast furnaces will be converted to eliminate most of the remaining CO2 emissions. This project demon- GRAPH 6: EU Emissions from Cement (MtCO2/year) strates some of the short- and long term thinking that Euro- pean industry must adopt (LKAB 2018). The steel sector at 150 large will only remain competitive if it manages to scale up these technological frontrunners and replace existing inef- ficient and carbon intensive furnaces. Without the proper 100 regulatory framework and high pollution costs, it is unlikely that the sector will move in this direction by itself. 50 Example: cement sector 0 1990 2000 2010 2020 2030 2040 2050 Cement production in the EU decreased in the wake of the financial crisis in 2008 and has not recovered since, standing Current trends at 67% of 1990 production in 2014 (Sterl et al 2017). Decarbonisation Steps towards circularity There are several options to reduce emissions in the cement Electricity-related emissions sector, which can be broadly grouped into four categories: Direct energy-related emissions clinker substitution, efficiency improvements, use of alterna- Process emissions tive fuels (both in direct energy and in the power sector), and demand reduction (IEA 2009 in Sterl et al 2017). Source: Sterl et al (2017) 16 EU ENERGY INTENSIVE INDUSTRIES: PAID TO POLLUTE, NOT TO DEC ARBONISE
Investment needed As these two examples demonstrate, industry and govern- Whenever public funding is made available for innovation, ment will need to make significant investments in research it should clearly be demarcated, so that it does not turn into and development and planning alternatives, as well as creat- general support for a firm’s day-to-day operations (and fol- ing a circular economy. Two core things must happen. Firstly, low the ignominious pathway of the EU ETS). governments need to drastically reconsider the current ap- proach of massive government subsidies for energy inten- Perhaps even more important than public research funds sive industry to pollute, and rather make them pay for pollu- is strengthening Europe’s “enabling environment”, that tion – both providing industry an incentive to invest and EU should stimulate capital investment, and facilitate promis- governments with funds to commit to innovation. Secondly, ing innovation to ensure that risk-bearing disruptive inno- both the private and public sector must invest in research, vations will create new markets and industrial leadership in development and deployment. These elements could be Europe (EC 2017d). complementary – for instance, tightening caps and auction- ing ETS emission allowances would raise an additional €120 Europe needs to stimulate more capital investment and billion in the period 2021-2030 (WWF 2016) which could be facilitate the uptake of promising innovation. Strength- allocated, in part, to industry innovation. ening Europe's enabling environment will ensure that its risk-bearing disruptive innovations will create new markets New policy approaches will be necessary, partly as revision and industrial leadership in Europe rather than outside (EC IV of the EU ETS has missed the most promising opportuni- 2017d). It could do this by following its own advice to clas- ties to reduce emissions and also as deep decarbonisation sify finance and investment in terms of their contribution to strategies for energy intensive industry are not able to be sustainability, encourage investment in areas of circular re- driven entirely by the EU ETS, with its far too low carbon source management (instead of the continuous throughput price. For instance, the steel sector is estimated at having of energy and materials), and instill long term thinking in abatement costs of between €100 and €500 per tonne of investment decisions (High Level Expert Group on Sustain- CO2 (CEPS 2017) – this compares with current EU ETS price able Finance 2018). of around €10 per tonne (Markets Insider 2018) and fore- cast price of €25 per tonne by 2030 (I4CE 2017). It is clear Most tools to stimulate and support industrial competi- that policies beyond carbon pricing are required to enable tiveness are available on the national and regional level. the development of new technologies in relevant time ho- The ambition to strengthen European industry at EU level rizons (CEPS 2017). therefore needs to be matched by national reform efforts, taking into account specific national and regional differenc- A part of this solution is the EU ETS Innovation Fund (for- es (EC 2017d). merly the New Entrants’ Reserve (NER) 300 Programme). In the past, the NER has allocated €2.1 billion and attracted €2.2 billion in additional private investment to 39 innova- tive projects. Thus in total about €4.3 billion (EC Nov 2017). For the period after 2020, ETS allowances are to be set aside for the Innovation Fund to support large scale demonstra- tion of innovative low carbon technologies for energy in- tensive industry, renewables, and carbon capture and stor- age (EC Sept 2017). These plans are expected to generate approximately €4.5 billion over 2021-2030. This is a good step in the right direction, but nowhere near the potential scale of what auctioning ETS permits could generate. Like- wise, it is neither close to investment levels needed, given that a single demonstration project can run to €1-2 billion (CEPS 2017). 17 EU ENERGY INTENSIVE INDUSTRIES: PAID TO POLLUTE, NOT TO DEC ARBONISE
The case of German Fat Cats8 In Germany, a wide array of measures is in place ensuring Between 2005 and 2016, industry received a total of more that energy intensive industry is well shielded from the than €159 billion subsidies in the form of rebates, ex- same costs and obligations that other market players and emptions and preferential tax treatment. These schemes households have to shoulder. have steadily increased since 2005. In 2016 alone, Germany provided direct and indirect sub- Broadly, German energy intensive industry benefits from sidies to energy intensive industry amounting to around schemes falling into four main categories: ETS-related €17 billion, which is about equal to Germany’s 2017 fed- subsidies, exemptions from energy and electricity taxes, eral budget on education and research and significantly exemptions from the German feed-in tariff for renewa- higher than the expected financial volume of the ETS Inno- bles and miscellaneous exemptions and rebates. vation Fund for the entire next trading phase 2021-2030.9 TABLE 3: Overview of direct and indirect subsidies to energy intensive industry in Germany, 2005-2016 Subsidy category 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 EU ETS 2365 1851 75 1987 1605 1649 1616 885 586 1098 1179 964 Energy/electricity tax 4132 4236 5066 5263 5374 5440 3837 4693 4432 4626 4482 4550 Feed-in tariff for RES 624 640 974 1138 1182 2086 3495 3583 5286 6844 6505 6523 Miscellaneous rebates 3603 3592 3576 3586 3575 3624 3901 4231 4466 4672 4791 4973 TOTAL 10724 10319 9691 11974 11736 12799 12849 13392 14770 17240 16957 17010 Source: Green Budget Germany (2017) 1. ETS-related subsidies 3. Exemptions from the German feed-in tariff Through free allowances and compensation schemes, the for renewables EU ETS provided subsidies to German industry of more In order to boost the market share of renewables in its than €950 million in 2016. This figure considers all free national energy mix, Germany has opted for the intro- allowances given to the industry as subsidies, irrespec- duction of a feed-in tariff. Under this scheme, the pro- tive of whether the sectors used them to cover their own ducers of renewables receive a fixed amount for their emissions or sold them on the market. energy sold on the market. Since this fixed price is high- er than the actual market price of energy, the differ- 2. Exemptions from energy and electricity taxes ence is paid through the feed-in tariff which is added to Germany also grants a number of rebates and exceptions everyone’s energy bill. A growing number of companies for its energy and electricity taxes to energy intensive in- has been granted either partial or total exemption from dustry. Currently, a total of 52,900 German companies ben- paying the tariff, depending on their energy-intensity. efit from special tax rebate which for example grant ben- In 2016, German energy intensive industry received eficiaries to pay a reduced electricity tax rate of 1.54 Ct/ around €6.5 billion in subsidies. kWh instead of the general rate of 2.05 Ct/kWh. In addition, certain processes applied in energy intensive sectors are 4. Miscellaneous exemptions and rebates even completely exempted from both electricity and ener- There are a number of additional measures in place. They gy taxes. Altogether preferential tax provisions for energy range from special rates on levies to support cogenera- intensive industry in 2016 amounted to €4.5 billion. tion and investors in offshore energy, to rebates for con- cession fees paid to local municipalities for making use of 8 The following section builds on an analysis of financial benefits to public infrastructure. While the latest amounts to an esti- energy intensive industry between 2005 and 2016 by the German Fo- rum Ökologisch-Soziale Marktwirtschaft (FÖS)/Green Budget Germa- mated subsidy of €6.5 billion per year, Green Budget Ger- ny: Green Budget Germany (2017). Ausnahmeregelungen für die In- many estimates the total of remaining rebate schemes to dustrie bei Energie- und Strompreisen - Überblick über die geltenden amount to €5 billion. Regelungen und finanzielles Volumen 2005-2016 (available in DE). http://www.foes.de/pdf/2017-04-FOES-Kurzanalyse-Industrieaus- nahmen-2005-2016.pdf 9 Assuming (very optimistically) an average carbon price of €30/tCO2 and a total of 450 million allowances set aside for the fund which is meant to finance low carbon technology demonstration projects, the Innovation will be worth €13.5 billion over the 2021-2030 period. 18 EU ENERGY INTENSIVE INDUSTRIES: PAID TO POLLUTE, NOT TO DEC ARBONISE
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